QUESTIONS AND ANSWERS A Supplement to the 2008 Continuum of Care Homeless Assistance NOFA and Application Office of Community Planning and Development U.S. Department of Housing and Urban Development Part III September 10, 2008
Table of Contents Section Subject Title Page A. Application 3 B. Special Initiatives 4 C. Projects 5 D. E. Renewal Funding Hold Harmless Need Reallocation 6 7-2 -
Questions and Answers A Supplement to the 2008 Continuum of Care Homeless Assistance NOFA and Electronic Application Additional information and training modules on the e-snaps system will be available at http://esnaps.hudhre.info/training/. CoCs may also contact the e-snaps Help Desk at esnaps@hud.hre.info or by calling 1-877-esnaps (1-877-637-6277). A. Application 1. Can a CoC submit an example of the most complete discharge planning protocol in the continuum for each system of care? HUD expects each CoC to demonstrate its progress in working with the appropriate local government entity to develop and implement a discharge planning policy for persons leaving publicly funded institutions or systems of care in order to prevent such discharge from immediately resulting in persons entering into the homeless system. In order to receive full credit, a CoC must show that the protocol is understood and agreed to by your CoC and the publicly funded institutions or systems of care in your geographic area. If the protocol varies in different geographic areas of a CoC, describe the protocol that is most developed for each category. A CoC s discharge planning protocol should be formulated through collaboration with state and local agencies and partners. The protocols should specifically address the guidelines used to prevent discharge into homelessness, (including the streets or McKinney-Vento funded programs) and must indicate where persons being discharged from this system of care routinely go. Please note that HUD is seeking information on the CoCs discharge planning protocols, and not that of a specific institution. 2. In previous years, CoCs only had to report on performance of those projects that were being renewed in that year s competition. Is this the same in 2008? No. In 2008, the Housing Performance section in e-snaps (Screen 4C and 4D) will now be calculated using data on all CoC projects that have submitted an APR, and not just this year s renewal projects. 3. How does a multi-jurisdictional CoC determine which jurisdiction to use to answer questions on HUD form 27300 Questionnaire for HUD s Removal of Regulatory Barriers? A CoC that covers multiple jurisdictions should submit the questionnaire for the local jurisdiction where the majority of its CoC assistance will be provided. The completed questionnaire must include appropriate documentation, where requested, and identify a point of contact. - 3 -
4. On screen 4C, under permanent housing, there is a new question which requests the number of participants who did not leave and were enrolled five months or less. Although the instructions indicate that CoCs should use APR data, the applicable APR question (12b) does not have a corresponding time frame. What timeframe should CoCs use to complete this question? For this question, please use data in the 1-2 month and 3-6 month time frames to determine the number of participants who did not leave and were enrolled for five months or less. 5. How should a CoC complete the third objective on screen 4A, if a CoC did not list a goal for Increase the percentage of homeless persons moving from TH to PH to at least 61.5%, because there is no McKinney-Vento funded Transitional Housing programs within the CoC? Screen 4A in e-snaps asks CoCs to provide performance data based on information that was provided in the 2007 application. Objective 3 in 2007 was Increase percentage of homeless persons moving from TH to PH to at least 61.5%. For those CoCs that indicted that no transitional housing facilities were located within the CoC and indicated not applicable for Objective 3, enter 100% in both the proposed achievement and actual achievement columns. B. Special Initiatives 1. If an emergency shelter is full and offers a family a hotel voucher for seven days, can that family qualify for the Rapid Re-Housing Program since an emergency shelter has paid for them to stay in a hotel for seven days? Yes. If an emergency shelter or other organization provides a family with a hotel voucher for seven days or more, the family may qualify for the Rapid Re-Housing program, so long as all other eligibility requirements are met. 2. During the time a family is receiving assistance from the Rapid Re-Housing Program, is the subsidy/voucher to pay their full rent with utility allowance or is the family responsible for paying up to 30% of their rent/utilities or is it up to the project sponsor/applicant to decide? Rapid Re-housing will be funded under the Supportive Housing Program (SHP) transitional housing component. Thus, the leasing subsidy will cover the rent and utilities if the lease includes utility costs, so long as the payment does not exceed the FMR amount. Under SHP, participants may be required to pay for up to 30% of their income towards leasing costs depending on how the program is designed - 4 -
3. In Rapid Re-Housing Projects, who holds the lease the sponsor or the participant? Also, are participants required to pay 30% of their income towards rent? Rapid Re-Housing projects will follow all SHP leasing requirements. Grantees may choose, based on program design, who will hold the lease the grantee, the sponsor, or the participant. Leasing funds cannot be given directly to the program participant. Additionally, for SHP projects (including Rapid Re-Housing projects), grant funds may be used to pay up to 100 percent of the rent charged by a property owner who is not the grantee or project sponsor. Participants may be required to pay up to 30 percent of their income for rent. See Section D of the updated SHP Desk Guide, which can be accessed on www.hudhre.info, for more information 4. Can Rapid Re-Housing project grantees accept households into their programs whose barriers exceed those defined in the NOFA, but who still have a good chance of maintaining housing successfully? Yes, Rapid Re-Housing grantees and project sponsors are to assess each potential household to determine if they meet the criteria for participation in the program. They can use the moderate barriers that were defined in the NOFA as a guideline for assessment, however each household should be considered on a case-by-case basis to determine eligibility. Households are expected to independently sustain housing, either subsidized or unsubsidized, at the end of the leasing subsidy; therefore, it is crucial that all households, particularly those whose barriers exceed those outlined in the NOFA, are appropriately assessed. 5. How many months after leaving the housing phase of a RRH project may a family continue to receive supportive services? Rapid Re-Housing project participants can continue to receive follow-up services from the housing program for up to six months after the family leaves the program. 6. Does a centralized intake already have to exist in CoCs applying for a Rapid Re- Housing project or can they propose a plan in the application? C. Projects Yes, a CoC that submits an application for a Rapid Re-Housing project must have an existing central intake as defined in the NOFA. CoCs that do not already have a system in place will not be considered. 1. Is Certification of Consistency with the Consolidated Plan voluntary for new or renewal Exhibit 2 projects? No, the Certificate of Consistency with the Consolidated Plan (Con Plan) is not voluntary but a required form for all Exhibit 2 projects. In 2008, HUD has determined that the Con Plan Certification can be submitted with a list of the projects - 5 -
and locations for each jurisdiction that the Con Plan covers. Each Con Plan and the list of projects it covers should be scanned and attached to the relevant SF-424. If the document is not attached it will be required before the conditional HUD award can be made. 2. Are domestic violence applicants required to disclose actual shelter locations? Domestic violence applicants are not required to include the actual shelter location address. Instead an administrative office address or a P.O. Box may be used. 3. Can client income benefits be used for leveraging? No, client income benefits cannot be counted towards leveraging however, for SHP, program income can be counted as leveraging. D. Renewal Funding 1. Can SHP grantees reduce the number of persons served to make up for higher costs associated with the project? Beginning with the 2006 Continuum of Care Homeless competition, if actual rents have increased substantially from the time of the initial application to the time of the first renewal, the grantee or project sponsor may need to reduce the number of units that can be supported by the project since the overall amount of the SHP request cannot be increased. Grantees that wish to reduce the number of units will be required at the grant execution phase or through a grant amendment to submit a written explanation that identifies the number of units that can be leased at the current fair market rent. Grantees should note that a reduction in the number of participants might result in a corresponding decrease in the other funded budget categories. For more information, see Section D of the updated SHP Desk Guide. 2. If an applicant submits an Exhibit 2 renewal budget with differences in line items that exceed 10 percent of what was submitted to HUD on the SHP Grant Inventory Worksheet, will HUD accept the new budget? No. Exhibit 2 budgets that are submitted with differences in line items of more than 10% from what was submitted to HUD in the CoC s SHP Grant Inventory Worksheet will be reversed back to the previously approved amounts. A Homeless Assistance listserv message was submitted on August 13, 2008, that contains all of the rules and guidance regarding budget changes for the 2008 CoC competition. - 6 -
E. Hold Harmless Need Reallocation 1. Can an eligible CoC reallocate funds into a new Safe Haven project? No. The Hold Harmless Need Reallocation process can only be used by eligible CoCs to create new permanent housing or dedicated HMIS grants. Safe Havens are not considered permanent housing and therefore, reallocated funds cannot be used to create this type of project. - 7 -